Telecom - Staff Letter addressed to the Distribution List
Gatineau, 2 May 2025
Reference: 8000-P114-202404929
BY EMAIL
Distribution list
Subject: Application by the British Columbia Ministry of Citizen’s Services to disclose certain Annual Facilities Survey data (8000-P114-202404929) - Request for Information
Dear recipients:
This letter sets out questions related to the application filed by the British Columbia Ministry of Citizens' Services (the BC Ministry) for the disclosure of certain data from the Annual Facilities Survey. In its application, the BC Ministry is requesting, among other things, that broadband and mobile wireless data – specifically, provider name, technology type, and speed – be made public, or be allowed to be made public in a way that can be searched by address at the 250-metre road segment. The BC Ministry referred to Innovation Science and Economic Development’s (ISED) broadband map as an example.
The BC Ministry notes that this level of public disclosure is critical to improving broadband transparency, addressing digital inequalities, and supporting evidence-based decision-making to guide strategic investments, particularly for underserved and rural communities. Additionally, access to this more granular data will enable Canadians to identify and choose the service provider that best meets their needs.
In response to the BC Ministry’s request, telecommunications service providers (TSPs) have raised concerns that making data available at such a granular level poses competitive and public safety risks, such as:
- Competitors may exploit detailed data to target investment strategies.
- Network infrastructure security could be compromised if service availability data were combined with other public sources.
- Insufficient restrictions on bulk address queries could allow automated scraping of provider-specific data. This will not only facilitate unfair competitive targeting (e.g., enabling rival service providers to identify areas with weak coverage zones), but also raise privacy risks if the scraped data, combined with additional open sources, can be used to map critical infrastructure.
Request for Information
The following questions are intended to build on parties’ submissions and to gather further information that will assist the Commission in evaluating the BC Ministry’s request.
For Provinces, Municipalities and Public Safety Organizations:
- How would access to data at the 250-metre road segment, such as provider name, technology type, and speed, support your mandate(s)? Specifically, how can this data be used to enhance public safety, inform emergency planning and coordination, and assist in infrastructure or service delivery decisions?
For Telecommunications Service Providers:
- Given that the exact locations of other telecommunications facilities, such as tower locations, are already publicly available, what specific, tangible harms could result from the public disclosure of broadband and mobile service data at the 250-metre road segment level or the location of transport facilities? Beyond general concerns (e.g. copper theft, competitive targeting, security), please describe in detail how such harms might materialize, including any past incidents that demonstrate tangible issues under the BC Ministry’s proposed format (i.e. searchable services by address)?
Granularity of Disclosure – All Parties:
- Given that the BC Ministry has requested public disclosure at the 250-metre road segment level, that precise tower locations are publicly available, and that other jurisdictions disclose more granular information (e.g. the Federal Communications Commission’s (FCC) National Broadband Map displays provider, technology, and speed data at the household level: FCC National Broadband Map), what level of geographic granularity (e.g., 250 m, 0.5 km, 1 km) would provide the appropriate balance between the public interest in disclosure and the protection of sensitive information?
Balancing Public Benefits and Identified Risks – All Parties:
- How should the Commission weigh the public interest in disclosure against the identified risks in deciding whether to approve the BC Ministry’s request in whole or in part?
Parties are requested to respond to every specific question that is directed to them, including questions that are directed to all parties, by 16 May 2025. Parties may then submit comments on those responses by no later than 2 June 2025. All documents filed must be received, not merely sent, by the date provided.
All related correspondence will be public. As set out in section 39 of the Telecommunications Act and in Broadcasting and Telecom Information Bulletin CRTC 2010-961, Procedures for filing confidential information and requesting its disclosure in Commission proceedings, persons may designate certain information as confidential. A person designating information as confidential must provide a detailed explanation for why the designated information is confidential and why its disclosure would not be in the public interest, including why the specific direct harm that would be likely to result from the disclosure would outweigh the public interest in disclosure. Furthermore, a person designating information as confidential must either file an abridged version of the document omitting only the information designated as confidential, or provide reasons why an abridged version cannot be filed. If filing confidential information, the Commission requires the response or other documents to be submitted electronically by using the secured service “My CRTC Account” (Partner Log In or GCKey) and filling the “Telecom Cover Page” located on the Commission’s website.
If you have any questions pertaining to this letter, please contact Bartek Bober by phone at (819) 230-0725 or by email at: bartek.bober@crtc.gc.ca.
Thank you, in advance, for your cooperation.
Sincerely,
Mark Allen
Senior Manager, Market Intelligence
Consumer, Analytics, and Strategy
c.c.: Bartek Bober, bartek.bober@crtc.gc.ca
Tom Blackwood, tblackw5@gmail.com
Tony Giligan, tony.gilligan@ecomm911.ca
Susan Church, susan.church@blueskyregion.ca
Ben Arril, ben.arril@gov.bc.ca
Cheryl Hansen, claude.innes@gnb.ca
Pierre Desmarteau, Pierre.Desmarteau@mce.gouv.qc.ca
Stefanie Corbett, lmacmillan@gov.pe.ca
LeBourdais, Maureen A, mlebourdais@cariboord.ca
Michael Riis-Christianson, michael.riischristianson@rdbn.bc.ca
Panneton Valérie, vpanneton@ctal.ca
Jonathan Veale, jonathan.veale@novascotia.ca
Rob Gay, rob11gay@gmail.com
Susan Clovechok, director.clovechok@rdek.bc.ca
Adela Wan, adela.wan@ontario.ca
Andrea Newell, anewell@houston.ca
Roel Coert, roel.coert@i-valley.ca
Owen Torgerson, otorgerson@valemount.ca
Walter Popoff, wpopoff@rdck.bc.ca
Nellie Davis, nellie.davis@rdbn.bc.ca
Ben Campbell, ben@northerndevelopment.bc.ca
Martin Elphee, district@fortstjames.ca
Reiko Tagami, rtagami@ubcm.ca
Warren Noga, warren@rmalberta.com
Johanna Helbig, jhelbig@coastalfirstnations.ca
Neil Smellie, neil@canwisp.ca
Judy Greenaway, judy.greenaway@rdbn.bc.ca
Michael McNally, mmcnally@ualberta.ca
Byron Holland, byron.holland@cira.ca
Bill Payne, bill.payne@haltonpolice.ca
Philippe Gauvin, bell.regulatory@bell.ca
Imran Mohiuddin, imran.mohiuddin@cybera.ca
Richard Bates, richard.bates@gov.ab.ca
Steve Mark, smark@icisociety.ca
Rob McMahon, info@firstmile.ca
Marielle Wilson, regulatory.matters@corp.eastlink.ca
Geoffrey (Geoff) White, gwhite@piac.ca
Andy Kaplan-Myrth, regulatory@teksavvy.ca
Jonathan Holmes, jonathan.holmes@itpa.ca
Kevin Spelay, document.control@sasktel.com
Howard Slawner, regulatory@rci.rogers.com
Cindy Wallace, cindy.wallace@xplore.ca
Erin Ruttan, erin.ruttan@calgary.ca
Kim Miller, kim.miller@telus.com
Melanie Cardin, regaffairs@quebecor.com
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